Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163 #00041

Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163 #00041

January 13, 2014

Submission Number:

00041

Commenter:

Nancy Brucks

State:

Maryland

Initiative Name:

Proposed Consent Agreement In the Matter of Service Corporation International and Stewart Enterprises, Inc.; File No. 131-0163

I appreciate the FTC's action with regard to SCI's merger with Stewart Enterprises. However, I remain deeply concerned about the FTC's proposed action of requiring the divestiture of Ed Sagel's Funeral Home -- a small player in our regional market, which is across the street from (and widely seen as dependent on and in the shadow of) the larger, SCI-owned Danzansky Funeral Home -- rather than of Hines-Rinaldi, with which the JFPC has been working well for a decade now. Though Sagel is closer to our synagogue, I cannot recall a single funeral that our community has held through them in recent years, versus dozens though Hines-Rinaldi. More than size, however, the real issue is of facilities. The real definition of 'regional market' here concerns those requiring the provision of traditional Jewish funeral services -- which in turn require specialized facilities for washing and dressing the body, which most funeral homes do not have, and which take some significant up-front investment to create. I have participated in ritual funeral preparation of a body at the Hines-Rinaldi home and was very pleased with the facility. Danzansky and Hines-Rinaldi -- which would both be owned by SCI under the proposed course of action -- have such facilities. Ed Sagel, whose future independence from SCI was meant to be the guarantor of competition and affordable options, does not. As such, the divestiture of Ed Sagel -- which much appreciated, and a step in the right direction -- does not truly protect this regional market, nor obviate the concerns of our community. With appreciation for all that you've already done, I join the chorus of voice surging you to go one step further: requiring the divestiture from SCI not of Ed Sagel, but of a full-service funeral home capable of meeting our community's needs, such as Hines-Rinaldi. Thank you.